Business expenditure deduction requires proof of genuine commission payments and commercial allowability; turnover growth alone cannot validate the cl...
Article 8 treaty coverage excluded third-party airline support services, while documented demonetisation cash receipts remained accepted business inco...
Functional comparability under TNMM requires highway contract benchmarks to reflect operation, maintenance and transfer activities, requiring fresh be...
Loss on valuation of foreign exchange contract on M2M basis - Loss on forward contracts - speculative loss - The AO disallowed the addition on the grounds that the losses were notional and did not represent actual losses. However, the Appellate Tribunal found that the losses were incurred as part of the appellant's business activities to hedge against foreign exchange fluctuations. The Tribunal relied on established legal principles and previous judgments to support its decision. Therefore, the addition was deleted. - The AO treated the loss on forward contracts as speculative, disallowing it for set-off against profits. However, the Tribunal disagreed, stating that the contracts were entered into to safeguard business interests, not for speculative purposes.
Loss on valuation of foreign exchange contract on M2M basis - Loss on forward contracts - speculative loss - The AO disallowed the addition on the grounds that the losses were notional and did not represent actual losses. However, the Appellate Tribunal found that the losses were incurred as part of the appellant's business activities to hedge against foreign exchange fluctuations. The Tribunal relied on established legal principles and previous judgments to support its decision. Therefore, the addition was deleted. - The AO treated the loss on forward contracts as speculative, disallowing it for set-off against profits. However, the Tribunal disagreed, stating that the contracts were entered into to safeguard business interests, not for speculative purposes.
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